State and Federal (This started in the new 2019 edition)
Description
The Most Complete, Form-Filled, Case-Filled, Cite-Filled, How-To Filled, Comprehensive Book On Discovery Ever Written. PERIOD. It thoroughly covers all weapons of discovery (Requests for Admissions, Interrogatories, Notices for Production and Inspection, Demands for Physical Examination, Depositions, and Subpoenas); it directs and guides all manner of submission and enforcement. Guerrilla Discovery is the only single source that has:
- Tons of explosive powerful forms for discovery demands, objections, and opposition
- Over 2,000 annotations with cites of key cases, authorities, and comments
- A unique annotated list of EVERY discovery defense/objection known to mankind
- Tactics, rules, decisions, statutes, tips, samples, checklists, and protocols
- An arsenal of strategies, counter-strategies, and anti-counter strategies
- Electronically Stored Information (ESI) resources, sources, and guides
- Pounds of sample interrogatories, RFA’s, notices, and demands
- Official eDiscovery court-approved protocols and conventions
- All approved official judicial counsel form interrogatories
- Coverage of predictive coding and technology-assisted review (TAR)
- Sample letters to smoke out every type of enemy obstructionism
- Valuable training for evidence and objections in general
- A step-by-step roadmap for noticing, taking, and defending depositions
- Guides for avoiding and handling dirty discovery tricks
- Key Rules uniquely and thoroughly Annotated
- Special Glossary for electronic and digital discovery
- An armada of case law supporting every key issue
- What to say, and what not to say at depositions and motions
- Basically – Everything you need for Discovery in one book
Guerrilla Discovery is a complete, comprehensive arsenal of information specifically tailored for planning, conducting and executing discovery. It likewise provides defensive information and counteroffensive chess-like strategies for every discovery attack. Guerrilla includes:
- Extensive Case Citations
- Updated Rules
- Detailed Strategies for the 6 Discovery Devices:
- Depositions
- Requests For Admissions
- Interrogatories
- Notice For Production
- Notice For Inspection
- Notice For Physical/Mental Examinations
- Model Forms (For all devices)
- Extensive Annotated Forms
- Comprehensive and Extensive Form Interrogatories
- Extensive Checklists
- A List of Every Possible Defense and Opposition to Discovery
- Sample Motion Arguments
- Sample Deposition Questioning
- Mini-Crash Courses in Evidence
Most lawsuits are engulfed in quarrelsome discovery fights. Coercion and confrontation are often necessary to obtain evidence on the hotly-contested issues. To help you win more of these important discovery skirmishes, Ashley Lipson’s Guerrilla Discovery offers dozens of clever strategies, novel arguments, direct answers, cautionary instructions, helpful timelines, tactically-annotated rules, and over one hundred innovative forms that will help you:
- Capture evidence establishing your claims and defenses
- Secure admissions
- Settle issues and disputes
- Impeach the opposition and its witnesses
- Uncover what the opposition is hiding
- Learn what the opposition has on you
- Handle defiant deponents and uncooperative attorneys
- Control the complexities of e-discovery
